Privacy Policy
This page explains what personal data we hold, why we hold it, and what you can ask us to do with it. It is written to be read, not to be survived.
Who we are
The controller of your personal data is Emic Lab A.M. Chodynicka, J. Więckowska s.c., Międzyborska 80, 04-010 Warsaw, Poland. DRIFT Partners is a practice of Emic Lab.
For anything on this page, write to amc@drift.partners.
When you write or call us
If you email us or call the number on this site, we hold what you send us: your name, your address or number, and what you wrote. We use it to reply and to carry the conversation on.
The legal basis is our legitimate interest in answering people who contact us (Article 6(1)(f) GDPR), and, where the conversation moves towards working together, the steps taken at your request before entering a contract (Article 6(1)(b) GDPR).
This site has no contact form. It collects nothing from you while you read it.
When we contact you first
We also hold the names and work contact details of people at organisations we have worked with, and at organisations whose work is close to what we do. The legal basis is our legitimate interest in offering our services to businesses (Article 6(1)(f) GDPR).
Where we did not get your details from you, we got them from one of the following: our earlier work together, someone at your organisation, your organisation's own website, or a professional network such as LinkedIn. We hold your name, role, organisation and work contact details, and nothing beyond that. You can ask us at any time which of these applies to you.
If you would rather we did not, tell us and we will stop. One line is enough.
How long we keep it
- Enquiries that do not lead to work: 24 months from our last exchange.
- Client records: for as long as the work runs, and afterwards for the period required by Polish accounting and tax law.
Who else sees it
Only the services that make this work possible: our email provider and the company that hosts this site. They act on our instructions under written data-processing agreements. They are:
- Microsoft 365 (Microsoft Ireland Operations Ltd), for email.
- Cloudflare, Inc. (United States), for hosting and site delivery.
- Google Ireland Limited, for site statistics.
We do not sell personal data and we do not share it for anyone else's marketing. Where a provider processes data outside the European Economic Area, that transfer is covered by the European Commission's standard contractual clauses.
Cookies and site statistics
To see whether anyone reads this site, we use Google Analytics, provided by Google Ireland Limited. It counts visits and shows us which pages are opened, and it sets cookies on your device.
It does not run until you say yes. On your first visit you are asked, and nothing is loaded until you choose. If you decline, or simply ignore the question, Google Analytics never starts and no analytics cookies are set. You can change your answer at any time through the Cookies link in the footer of every page.
We use it for audience statistics only. We do not run advertising, we do not build advertising profiles, and we do not share what it collects for anyone else's marketing. Cloudflare, which delivers this site, also sets a security cookie that protects it from automated traffic; that one is necessary for the site to work and is not used to identify you.
Your rights
You can ask us to show you what we hold, correct it, delete it, or limit what we do with it. You can ask for a copy in a portable form. You can object to any processing we base on legitimate interest, including everything described under "When we contact you first".
Write to amc@drift.partners. We answer within one month.
If you think we have got it wrong, you can complain to the Polish supervisory authority: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl.
Changes
If this policy changes, the new version appears here with a new date. If the change matters to you, we will say so when we next write.